Terms of Use

1. Identification of the provider

The provider of the services regulated in these Terms and Conditions is:

• Company name: RINTRAL TRADING SL S.A.

• Trade name: NEBEUS

• Tax ID number: 30-71886661-4

• Legal address: Ingeniero Enrique Butty 240 Piso 7, Laminar Plaza, C1001, Autonomous City of Buenos Aires, Argentine Republic

• Contact email: info@nebeus.ar

• Applicable registration: Virtual Asset Service Provider (VASP) — CNV No. 145

2. Acceptance of terms

This document sets forth the General Terms and Conditions (hereinafter, the "Terms and Conditions") governing access to and use of the digital platform operated by RINTRAL TRADING SL S.A., under the trade name NEBEUS ("NEBEUS" or the "Provider").

Access, browsing, registration, and use of the services imply full, express, informed, and unequivocal acceptance of these Terms and Conditions by any person acting as a user ("User"). Acceptance may be formalized by:

• Checking checkboxes,

• Clicking on confirmation buttons,

• Entering credentials during registration, or

• Any other technical means of expressing valid consent in accordance with applicable law.

If the User does not agree in whole or in part with these Terms and Conditions, they must refrain from using the Platform.

Likewise, the User declares and guarantees that they have sufficient legal capacity to enter into contracts and that they are acting on their own behalf, or as a duly authorized representative of a legal entity, assuming in both cases all obligations arising from the use of the Platform.

3. Definitions

For the purposes of these Terms and Conditions:

• Platform: the website, mobile application, interfaces, APIs, and other digital services operated by NEBEUS.

• Services: all functionalities enabled on the Platform, including but not limited to opening an account on the Platform, identity verification, digital custody, execution of electronic transactions, conversion between fiat currencies and virtual assets, sending and receiving transfers linked to the Services, as well as others that may be incorporated in the future.

• User: any natural person over the age of 18 with legal capacity who accesses or uses the Platform, as well as legal entities that contract the Services through their authorized representatives.

• Account: the individualized digital profile created on the Platform, associated with registration data, access credentials and, where applicable, linked funding or withdrawal methods.

• Virtual Assets: digital representations of value that can be transferred, stored, or traded electronically, including cryptocurrencies, stablecoins, and other tokens supported on the Platform, in accordance with current regulations.

• Third-Party Providers: individuals or legal entities that provide services to NEBEUS as data processors or sub-processors (e.g., identity validation, fraud prevention, payment gateways, cloud storage, custody, or analytics).

• Complementary Policies: the Privacy Policy, the Cookies Policy, and any other notice or regulation published on the Platform, which form an integral part of these Terms and Conditions.

4. Purpose of the Service

The Platform offers digital services related to the management of virtual assets, including the opening and administration of accounts on the Platform, identity verification (KYC), the implementation of measures for the prevention of illegal operations (AML), the execution of electronic transactions, digital custody, conversion between fiat currencies and virtual assets, and other complementary functionalities that may be incorporated in the future. The User expressly acknowledges and accepts that:

• We are not a financial or banking institution. NEBEUS does not accept deposits from the public, does not offer regulated savings products, and does not provide services typical of financial institutions authorized in the Argentine Republic.

• We do not provide financial, legal, or tax advice. Any decision to invest, convert, or use virtual assets is made exclusively by the User at their own risk.

• Virtual assets do not have legal tender status in Argentina. Their acceptance as a means of payment or transaction depends on the willingness of the parties involved and the regulations in force in each jurisdiction.

• Geographical restrictions may apply. Certain features, particularly those related to stablecoins, may not be available to users residing in the European Union in compliance with Regulation (EU) 2023/1114 (MiCA) and other applicable local or international regulations.

• The services are subject to change. NEBEUS may modify, expand, suspend, or interrupt, temporarily or permanently, any of the Platform's features, notifying Users in a timely manner when appropriate.

Use of the Services implies full acceptance of the scope and limitations described herein.

5. User Registration and KYC/AML Verification

Access to NEBEUS Services is reserved for individuals over the age of 18 with full legal capacity to contract under Argentine law. To use the Platform, the User must complete a registration process, provide truthful, complete, and up-to-date information, and expressly accept these Terms and Conditions, as well as the Privacy Policy and Cookies Policy. Registration is personal and non-transferable, and each User is responsible for the safekeeping of their access credentials and for all activity carried out under their Account.

In compliance with Law No. 25,246 and the regulations of the Financial Information Unit (UIF), as well as international standards for the prevention of money laundering and terrorist financing, NEBEUS may require the submission of additional documentation—such as official identification, proof of address, proof of income, or sworn statements—verify the authenticity of the information through specialized providers, and continuously monitor the operations carried out on the Platform. These measures are intended to contribute to the legality and security of operations and will allow limits of use to be established or transactions to be blocked when there are indications, alerts, or unusual patterns.

If the User provides false, incomplete, or inaccurate information, uses the Platform for illegal purposes or purposes contrary to public order, or if there are instructions from judicial or regulatory authorities, NEBEUS may temporarily or permanently suspend, limit, or cancel the Account, without this giving rise to any right to compensation and without prejudice to the corresponding legal actions. Likewise, the creation of multiple accounts for fraudulent purposes or with the aim of circumventing security controls is expressly prohibited.

The User agrees to keep their information permanently updated and acknowledges that failure to comply with these obligations may result in the immediate restriction of the Services.

The User acknowledges that NEBEUS may be legally prevented from informing them if a report has been made to the UIF or if an investigation is ongoing.

6. Risks associated with virtual assets

The User acknowledges and accepts that the use of virtual assets entails specific risks, both technological and financial and regulatory, which are beyond the direct control of NEBEUS. These include, but are not limited to, the volatility of asset prices, the possible illiquidity of certain markets, the possibility of technological forks, network or protocol failures, software or hardware security vulnerabilities, as well as possible regulatory restrictions that may limit the availability or use of certain services.

Furthermore, within the framework of the regulations of the Financial Information Unit (UIF), the company applies a Risk-Based Approach (RBA) in accordance with UIF Resolution No. 49/2024 and the recommendations of the FATF. This means that User transactions are subject to monitoring controls, due diligence, and analysis of unusual patterns, and limits may be established, transactions may be rejected, or accounts may be blocked when signs of high risks of money laundering, terrorist financing, or illegal activities are detected.

In accordance with its Risk Tolerance Statement approved by the Board of Directors, NEBEUS seeks to operate with low residual risk levels and, consequently, will adopt immediate mitigation plans in cases where medium or high risks are identified. This may result in the temporary suspension of operations, the request for additional information from the User, or the permanent restriction of access to the Platform.

The User understands that these measures do not constitute a breach of contract by NEBEUS, but rather a legal and regulatory obligation arising from its status as a Virtual Asset Service Provider (VASP) registered with the National Securities Commission (CNV).

Finally, the User accepts that investments and transactions with virtual assets are not backed by the state or guaranteed by any official body, and that their value may experience total or partial losses. Under no circumstances shall NEBEUS be liable for such variations or for any damages that may arise from them.

7. Platform Products and Services

In addition to the general services of opening and managing digital accounts, custody of virtual assets, and execution of electronic transactions, the NEBEUS Platform may currently or in the future offer various products and functionalities related to virtual assets and technological services. Such products include, but are not limited to:

• Conversion between fiat currency and virtual assets, including stablecoins, subject to liquidity availability, market conditions, and regulatory restrictions in force in each jurisdiction. The User acknowledges that the price of virtual assets and stablecoins may vary in real time and that NEBEUS does not guarantee a fixed reference value or future stability.

• Stablecoins issued by third parties, whose acceptance, liquidity, and operation will depend on the infrastructure and solvency of the respective issuer. NEBEUS does not guarantee or endorse the value of such stablecoins, nor does it assume any redemption obligation to the User, except for the execution of transactions validly processed on the Platform.

• Benefit, reward, or referral programs, which may include bonuses in virtual assets, discounts on commissions, or similar benefits. Such programs are promotional and temporary in nature and do not constitute acquired rights and may be modified or eliminated by NEBEUS at any time.

• Debit, credit, or prepaid cards associated with digital accounts, whose issuance, settlement, and operation will be handled by duly authorized financial institutions or external processors. The use of such cards will be subject to the specific terms and conditions of the issuer, and NEBEUS assumes no responsibility for failures, rejections, or delays attributable to such third parties.

• Complementary technological services, such as analysis tools, transaction reports, operational alerts, or integration with external applications, which are provided on an ancillary basis and may be modified or interrupted without prior notice.

The User acknowledges and accepts that all products and services offered on the Platform:

1. Do not constitute bank deposits or financial instruments regulated by the Central Bank of the Argentine Republic (BCRA), the National Securities Commission (CNV), or other local financial agencies.

1. Are subject to additional specific conditions, which must be read and expressly accepted in each case before use.

1. May be modified, restricted, suspended, or eliminated at any time, at the sole discretion of NEBEUS, without giving rise to any right to indemnification, compensation, or reimbursement for the User.

1. They involve additional risks—such as loss of promotional benefits, variations in conversion costs, regulatory changes affecting the availability of stablecoins, or suspension of services by third-party issuers—which are assumed entirely by the User under their sole responsibility.

In the event of any contradiction between these General Terms and Conditions and the specific terms of a given product, the latter shall prevail where applicable.

8. Fees, commissions, and taxes

Access to the Platform may involve the payment of fees and commissions for the provision of certain Services. These fees will be communicated clearly and transparently through the Platform itself, in specific pricing sections or at the time of confirming each transaction. NEBEUS reserves the right to modify the fees at any time, ensuring that the changes are published sufficiently in advance and are applicable only to transactions carried out after their entry into force.

Commissions may be expressed in legal tender (Argentine pesos) or in virtual assets, depending on the nature of the service. The User acknowledges and accepts that, in transactions with virtual assets, the final value may be affected by market volatility, available liquidity, and network costs ("gas fees" or blockchain commissions), circumstances beyond the control of NEBEUS.

The User is solely responsible for complying with their tax obligations arising from the use of the Services, including the declaration and payment of taxes, fees, or contributions that may be applicable in their jurisdiction. NEBEUS does not act as a withholding agent and assumes no responsibility for the User's tax obligations, except in those cases where Argentine regulations expressly impose such an obligation.

In certain cases, NEBEUS may offer promotions, discounts, or bonuses, which will be announced in advance and will be valid for a limited time. These promotional conditions do not alter the Provider's right to receive the ordinary fees and commissions once the corresponding promotion has ended.

9. Payments, refunds, and chargebacks

Payments made through the Platform are considered firm, final, and irrevocable, unless expressly provided otherwise by law. The User acknowledges that transactions with virtual assets are, by their nature, irreversible once confirmed on the blockchain network, and that there is no right of withdrawal or obligation of automatic refund.

No refunds will be granted for market price variations, User errors (including incorrect wallet addresses), or delays resulting from network congestion or third-party systems. Only in exceptional cases, and at NEBEUS' sole discretion, may a refund be considered if a technical error directly attributable to the Platform is demonstrated. In such cases, the refund will be processed using the same payment method as the original transaction, unless otherwise agreed in writing.

The User agrees to resolve any discrepancies directly with NEBEUS before initiating a chargeback with their bank or card issuer. Abusive or unfounded chargebacks may result in the immediate suspension or cancellation of the Account, as well as the retention of available funds as compensation. NEBEUS may also claim reimbursement from the User for the costs, administrative charges, and damages caused by the improper chargeback.

Chargebacks will only be accepted in cases of unauthorized charges, proven fraud, or technical errors recognized by NEBEUS. Under no circumstances will chargebacks related to validly confirmed blockchain transactions or losses resulting from market volatility be accepted.

The User understands that filing chargebacks without legitimate cause constitutes a serious breach of these Terms and Conditions, which entitles NEBEUS to take appropriate legal action.

10. Permitted use of the Platform and prohibitions

The User agrees to use the Platform and NEBEUS Services in accordance with current legislation, these Terms and Conditions, and contractual good faith. Consequently, any use that is unlawful, fraudulent, or that may jeopardize the security, stability, or reputation of the Platform and its users is strictly prohibited.

In particular, the following, by way of example, shall be considered prohibited conduct:

• The use of the Platform to carry out illegal activities, including operations related to money laundering, terrorist financing, financial fraud, pyramid schemes, or other economic crimes.

• Registering multiple accounts to circumvent security controls, take advantage of promotions in an abusive manner, or artificially manipulate transactions or benefits.

• The use of false identities, impersonation, or the provision of inaccurate, incomplete, or falsified data during the registration process or while using the Services.

• Technical manipulation of the Platform through reverse engineering, code injection, computer attacks, bots, or any other practice intended to breach the security of the systems or alter their operation.

• Sending unauthorized commercial communications, disseminating offensive or defamatory content or content contrary to public order, as well as any activity that may negatively affect the experience of other users.

NEBEUS reserves the right to immediately suspend, limit, or cancel, without prior notice, the Account of any User who engages in the conduct or other equivalent conduct, without this giving rise to any right to compensation. The suspension or cancellation shall be without prejudice to any civil, administrative, or criminal actions that may be applicable.

The User acknowledges and accepts that NEBEUS may implement automated fraud detection and transaction monitoring tools, as well as share information with competent authorities and specialized providers, in compliance with its regulatory and contractual obligations.

11. Custody, wallets, and operations

Users' virtual assets may be held under digital custody schemes provided directly by NEBEUS or through specialized third-party providers, in segregated or omnibus mode, depending on the technical conditions of the service. In the case of omnibus custody, the assets of different Users may be stored in collective addresses, without prejudice to the internal records that identify the individual ownership of each User. The User acknowledges and accepts that:

1. Virtual assets do not constitute bank deposits and are not covered by the deposit insurance of the Central Bank of the Argentine Republic (BCRA).

1. Digital custody depends in part on external infrastructures (blockchains, validators, technology providers) over which NEBEUS has no direct control.

1. In the event of network failures, hacks, forks, airdrops, or alterations to external protocols, NEBEUS shall not be liable in any case for losses, delays, or inability to access funds, except in cases of fraud or gross negligence directly attributable to the Platform. Likewise, NEBEUS is not obliged to automatically recognize tokens derived from forks, airdrops, or other technical events, unless expressly stated otherwise.

1. The User may transfer virtual assets to and from external wallets not held by NEBEUS, under their sole responsibility. NEBEUS shall not be liable for failed transactions, delays, or losses resulting from incorrect addresses, incompatible networks, or vulnerabilities in third-party wallets.

1. To ensure security and comply with anti-money laundering and counter-terrorism financing obligations (UIF, CNV, and where applicable, BCRA), NEBEUS may implement additional measures such as security delays ("cooling-off periods"), manual verifications, temporary blocks, or requests for documentation before executing withdrawals to external wallets.

Opening an Account on the Platform does not imply, in any case, the opening of a bank account or the creation of a deposit regulated by the Argentine financial system. The balances in virtual assets reflected on the Platform correspond exclusively to the digital availability managed through the technological custody infrastructure, and are not covered by state guarantees or deposit insurance.

Transactions carried out on the Platform—including transfers, conversions, purchases, sales, or withdrawals of virtual assets—will be subject to the technical conditions of the blockchain networks involved, as well as the availability of liquidity and the operating limits established by NEBEUS in compliance with its internal risk management policies. The User acknowledges that such transactions may be irreversible once validated on the network and that any technical failures, congestion, or delays inherent to the underlying technology are beyond the Provider's control.

NEBEUS may apply additional security measures, such as two-step verification, dynamic passwords, or manual validations, reserving the right to suspend or delay the execution of transactions when there are indications of fraud, hacking, operational error, dubious instructions, or requests from competent authorities.

The User is solely responsible for the instructions they issue through the Platform and declares that they understand that the custody and management of virtual assets involve inherent risks, which they assume in full and without the possibility of claiming compensation for changes in value, loss of liquidity, forks, airdrops, or failures inherent to decentralized networks.

12. Intellectual property

All intellectual and industrial property rights relating to the NEBEUS Platform, including but not limited to the design, interfaces, source code, software, databases, trademarks, logos, trade names, content, manuals, and associated documentation, belong to RINTRAL TRADING SL S.A. (NEBEUS) or its authorized licensors.

Access to and use of the Platform does not grant the User any right of ownership or use other than that strictly necessary for the proper use of the Services under the terms set forth in these Terms and Conditions. The reproduction, distribution, public communication, transformation, reverse engineering, decompilation, or any other form of exploitation, in whole or in part, of the content and elements protected by intellectual property rights is expressly prohibited without the prior written authorization of NEBEUS.

The User undertakes to always respect the intellectual property rights of NEBEUS and third parties, agreeing to refrain from any conduct that may infringe upon them. In the event of non-compliance, NEBEUS may immediately take the necessary technical and legal measures, including suspending the Account and initiating legal action to defend its rights.

Likewise, the User acknowledges that the trademarks and distinctive signs associated with NEBEUS constitute high-value reputational assets, the unauthorized use of which will give rise to direct liability and compensation for damages.

13. Liability, limitations, and indemnity

NEBEUS will provide the Services with a reasonable level of diligence and security, but does not guarantee uninterrupted availability or the absence of technical errors on the Platform, insofar as such contingencies may arise from factors beyond its control, such as telecommunications network failures, third-party system crashes, vulnerabilities in blockchain protocols, network congestion, cyber-attacks, or force majeure events.

The User acknowledges and accepts that virtual assets are highly volatile and risky, and that their value may fluctuate sharply or even be lost entirely. NEBEUS is not responsible for economic, tax, or financial losses resulting from market variations, lack of liquidity, investment decisions made by the User, or adverse regulatory interpretations in other jurisdictions.

Under no circumstances shall NEBEUS be liable for:

• Loss of profits, loss of business opportunities, indirect, incidental, or consequential damages.

• Damages resulting from the User's misuse of the Platform, including failure to comply with these Terms and Conditions or the operating instructions provided.

• Regulatory breaches attributable to the User, such as failure to file tax returns or participation in illegal activities.

The User shall indemnify and defend NEBEUS, as well as its officers, employees, and suppliers, against any claim, penalty, fine, damage, or harm arising from the misuse of the Platform, the provision of false or incomplete information, or the performance of operations prohibited by applicable regulations.

Nothing in this clause limits the liability that may correspond to NEBEUS for willful misconduct or gross negligence, under the terms of applicable Argentine law.

14. Additional disclaimers of liability

The User expressly acknowledges and accepts that:

1. **Volatility and liquidity** - Virtual assets are highly volatile and their value may fluctuate sharply, even to the point of losing their economic value entirely. NEBEUS does not guarantee the liquidity, availability, or market price of the assets traded on the Platform.

1. **External technical events** - NEBEUS shall not be liable for consequences arising from network forks, new token launches, airdrops, changes in consensus algorithms, software updates, errors in smart contracts, or any other technical event related to external infrastructures over which it has no control. The accreditation or non-accreditation of tokens derived from forks or airdrops will be determined at the sole discretion of NEBEUS and does not constitute a contractual obligation unless expressly stated otherwise.

1. **Dependence on third parties** - The operation of the Platform may depend on external providers (payment gateways, financial institutions, blockchain networks, custodians, cloud providers, validators, stablecoin issuers). NEBEUS shall not be liable for any failures, delays, losses, or damages arising from the actions or omissions of such third parties.

1. **User errors** - NEBEUS shall not be liable for errors made by the User, including incorrect wallet addresses, selection of incompatible networks, errors in the amount or transfer instructions, loss of private keys in external wallets, or negligence in protecting credentials.

1. **No guarantee of results** - NEBEUS does not guarantee that the use of the Platform will generate economic benefits, return on investment, or preservation of the value of virtual assets.

1. **Force majeure and regulations** - NEBEUS shall not be liable for losses or inability to use the Services resulting from force majeure events, economic sanctions, regulatory changes, orders from judicial or administrative authorities, or the imposition of new legal restrictions affecting virtual assets or fintech services.

15. Electronic communications, modifications, and assignment

All communications between NEBEUS and the User shall preferably be made by electronic means. To this end, the User expressly authorizes the receipt of notifications at the email address registered in their Account, through messages within the Platform, or through push notifications in the mobile application. Such communications shall be deemed to have been validly made on the date of their dispatch, unless proven otherwise.

**Modifications**. NEBEUS may modify these Terms and Conditions at any time to adapt them to regulatory, technological, operational, or commercial changes. The modifications will be published on the Platform and will take effect from the date indicated in the new version. In the case of substantial changes that may significantly affect the User's rights, this will be communicated prominently through the Platform or by email. Continued use of the Services after the new version comes into effect will imply acceptance of the updated Terms and Conditions.

**Assignment.** NEBEUS may assign, transfer, or delegate the contractual position derived from these Terms and Conditions to any third party or affiliated company, notifying Users in advance via the Platform or by email. The User, for their part, may not assign or transfer their rights or obligations derived from these Terms without the prior written consent of NEBEUS.

16. Applicable law, jurisdiction, and final provisions

These Terms and Conditions shall be governed by and interpreted in accordance with the laws in force in the Argentine Republic. For any dispute related to their validity, interpretation, compliance, or enforcement, the parties expressly submit to the jurisdiction of the ordinary courts located in the Autonomous City of Buenos Aires, waiving any other jurisdiction that may apply.

The possible nullity, invalidity, or ineffectiveness of any of the provisions contained in these Terms and Conditions shall not affect the validity of the remaining provisions, which shall remain in full force and effect.

The failure of NEBEUS to exercise or enforce any right or power provided for in these Terms and Conditions shall not constitute a waiver thereof, unless expressly acknowledged in writing.

In the event of any discrepancy between these Terms and Conditions and any policy, notice, or supplementary document published on the Platform, the provisions herein shall always prevail, without prejudice to the application of mandatory regulations on consumer protection and personal data protection.

17. Absence of fiduciary or advisory relationship

The User acknowledges and accepts that the use of the Platform and the Services does not create a fiduciary, agency, or advisory relationship of any kind between the User and NEBEUS. The service is merely one of execution and does not include financial, legal, accounting, or tax advice, unless expressly indicated in specific product documentation. The User is solely responsible for assessing the suitability, risks, and implications of each transaction instructed through the Platform.

18. Disclaimer of warranties ("as is" and "as available")

To the fullest extent permitted by applicable law, the Platform and Services are provided "as is" and "as available," without warranties of any kind—express, implied, statutory, or otherwise—including, without limitation, warranties of merchantability, fitness for a particular purpose, or non-infringement. NEBEUS does not guarantee uninterrupted availability or the absence of errors, delays, vulnerabilities, or interruptions caused by third parties, telecommunications networks, or blockchain protocols.

19. Quantitative limit of liability

Without prejudice to the provisions of Clause 10 (Liability, Limitations, and Indemnity) and except in cases of willful misconduct or gross negligence, NEBEUS's total aggregate liability for any claim arising out of or related to these Terms and the use of the Platform shall not exceed the total fees actually paid by the User to NEBEUS during the twelve (12) months prior to the event giving rise to the claim. Nothing in these Terms excludes or limits liabilities that cannot be limited under applicable law.

20. Claims and internal resolution procedure

NEBEUS has an internal procedure for handling claims. The User may submit their claim through the Platform's Support Center or by email to legal@nebeus.com.ar, indicating name and contact details, account ID, detailed description of the event and relevant dates, supporting documentation (receipts, screenshots), and the requested solution.

Once the complaint has been received, acknowledgment of receipt will be sent, and an internal investigation will be initiated. NEBEUS will endeavor to resolve the matter within 30 business days, extendable to 60 business days in complex cases or if additional information is required. The period begins once the documentation is complete. The proceedings may be escalated to the Compliance Department and/or the Legal Department, as appropriate.

21. Retention of complaint documentation

All documentation related to complaints will be kept securely for a period of three (3) years, or for a longer period if required by current regulations or a regulatory investigation. After this period, the information will be securely deleted or anonymized, in line with the Privacy Policy.

22. Personal data protection

The processing of Users' personal data is governed by Law No. 25,326 on Personal Data Protection and its regulatory standards. RINTRAL TRADING SL S.A., under the trade name NEBEUS, acts as the data controller, with registered office in the Autonomous City of Buenos Aires, Argentine Republic.

The data collected will be used exclusively for purposes related to the provision of Services, including account management, identity verification (KYC), prevention of illegal transactions (AML), compliance with regulatory obligations and, where applicable, sending operational or contractual communications.

Users may exercise their rights of access, rectification, updating, and deletion of their data (ARCO rights) at any time, in accordance with Article 14 of Law 25,326, by sending an email to privacy@nebeus.com.ar or through the channels enabled on the Platform.

NEBEUS declares that it has adopted the necessary technical and organizational measures to guarantee the security, confidentiality, and integrity of the information, and that it will not share personal data with third parties, except with providers who provide services necessary for the operation of the Platform and the provision of the Services, who will process the data on behalf of NEBEUS, or when there is a legal obligation or express consent from the User.

Full details on the processing of personal data can be found in the NEBEUS Privacy Policy, which forms an integral part of these Terms and Conditions.

23. Regulatory notifications and technical cooperation

The User acknowledges and accepts that NEBEUS, in its capacity as a Virtual Asset Service Provider (VASP) registered with the National Securities Commission (CNV), is subject to the obligations imposed by the Financial Information Unit (UIF), the Customs Collection and Control Agency (ARCA) (formerly AFIP) and other competent national agencies, as well as to international cooperation commitments within the framework of bilateral agreements and the recommendations of the Financial Action Task Force (FATF).

In compliance with these obligations, NEBEUS may:

• Block, suspend, or delay transactions when there are reasonable indications of money laundering, terrorist financing, fraud, or other economic crimes, or when instructed to do so by competent authorities.

• Freeze, in whole or in part, funds or virtual assets held in custody when so ordered by domestic or foreign judicial, regulatory, or administrative authorities, pursuant to a valid request in accordance with applicable regulations.

• Share information with the aforementioned authorities, both national and international, when required by current regulations or international treaties to which the Argentine Republic is a party.

• Implement enhanced controls and reporting on transactions involving countries, persons, or entities classified as high risk or included in financial sanctions lists (e.g., OFAC, European Union, United Nations).

The User accepts that these measures constitute unavoidable legal obligations of NEBEUS and do not give rise to any right to indemnification, compensation, or liability on the part of the Provider.

Likewise, the User agrees to cooperate fully if required to provide additional information, supporting documentation, or sworn statements necessary for compliance with these regulatory obligations.

24. Precautionary measures and cross-border cooperation

Nothing in these Terms shall prevent NEBEUS from seeking precautionary or provisional measures before any jurisdiction when necessary to protect its rights, prevent imminent harm, or prevent the disposal of virtual assets allegedly involved in fraud or other illegal activities. This power is understood to be complementary to the jurisdiction agreed upon in Clause 12, and without prejudice to the duties of cooperation with domestic and foreign administrative, judicial, or regulatory authorities.

25. Version control and availability of the Terms

These Terms are subject to version control and archiving. The current version will always be available on the official NEBEUS website, indicating its effective date. Continued use of the Platform after that date will imply acceptance of the updated version. If the User does not agree with the changes, they must stop using the Services and request the closure of their Account in accordance with the applicable provisions.

26. Term and termination of the contract

The contractual relationship between the User and NEBEUS arising from the acceptance of these Terms and Conditions is of indefinite duration, as long as the User keeps their Account active and uses the Platform Services.

The User may request the voluntary termination of the contractual relationship and the closure of their Account at any time, if there are no pending transactions or unfulfilled obligations. The request must be made through the channels enabled on the Platform and will take effect once processed by NEBEUS, which may require additional security or regulatory compliance checks (KYC/AML).

For its part, NEBEUS may suspend or terminate, in whole or in part, the contractual relationship and access to the Platform in the following cases:

• Breach of these Terms and Conditions, the Privacy Policy, the Cookies Policy, or any applicable regulations.

• Reasonable evidence of misuse, illegal or fraudulent use of the Platform.

• Requirement by judicial, administrative, or regulatory authorities, whether domestic or foreign.

• Persistent prolonged inactivity of the Account for a period exceeding twelve (12) months.

• Closure or structural modification of the Services offered by NEBEUS.

In the event of termination for any reason, the User may withdraw the funds available in their Account, unless this contravenes regulatory orders or blocks imposed by competent authorities, in which case NEBEUS may freeze or restrict all or part of the funds for the scope and term determined by such orders. Outside of these cases, NEBEUS may retain all or part of the funds up to the amount of outstanding obligations, chargebacks, reasonable costs arising from disputes, or compliance with requirements in the context of ongoing regulatory investigations.

The termination of the contractual relationship does not exempt the User from the responsibilities, obligations, or debts incurred prior to the effective date of closure of the Account.

The provisions of this clause are understood to be without prejudice to the powers of immediate suspension or termination provided for in Clause 27.

27. Suspension and termination of accounts

NEBEUS may suspend, restrict, or terminate, temporarily or permanently, a User's Account and their access to the Platform, without the need for judicial authorization or any liability for damages, in any of the following cases:

1. Breach of contract. When the User breaches, in whole or in part, these Terms and Conditions, the Privacy Policy, the Cookies Policy, or other complementary policies.

1. Prevention of illegal activities. When there are reasonable indications of use of the Platform for illegal or fraudulent purposes, contrary to public order, linked to money laundering, terrorist financing, or violations of international sanctions.

1. Prolonged inactivity. When the Account remains inactive for a period exceeding twelve (12) months, without prejudice to NEBEUS' obligation to keep records in accordance with applicable regulations.

1. Requirement by authorities. When ordered by judicial, administrative, or regulatory authorities, whether domestic or foreign, within the scope of their legal powers.

1. Improper chargebacks or abusive disputes. When the User initiates chargebacks without legitimate grounds, makes repeated claims in bad faith, or causes economic or reputational damage to NEBEUS.

1. Platform security. When attempts at hacking, technical manipulation, unauthorized access, identity theft, or any activity that may affect the integrity or availability of the system are detected.

Preventive suspension may be applied for the time necessary to carry out the relevant verifications. In the event of definitive termination, NEBEUS may retain funds up to the corresponding amount as compensation for damages, chargebacks, or fines imposed by the competent authority, and shall inform the User of the reasons for the measure unless there is a confidentiality order from the competent authority.

Termination of the Account does not exempt the User from outstanding obligations or extinguish liability for events that occurred prior to closure.

28. Force majeure

NEBEUS shall not be liable for any failure, delay, suspension, or interruption in the provision of the Services when these are the result of force majeure events or circumstances beyond its reasonable control.

By way of example only, the following constitute cases of force majeure: natural disasters, fires, floods, earthquakes, epidemics or pandemics, acts of war or terrorism, labor disputes, power or telecommunications outages, widespread failures in computer systems or external suppliers, massive cyberattacks, decisions by regulatory or judicial authorities, international blockades, financial sanctions, exchange restrictions, or any other unforeseeable or unavoidable event that totally or partially prevents the normal performance of the Services.

During the duration of a force majeure situation, NEBEUS may temporarily suspend the affected Services without incurring any liability, penalty, or compensation to the User. Once the cause of the suspension has ceased, the service will be restored to the extent possible.

If the force majeure situation lasts for more than ninety (90) calendar days, either party may terminate the contractual relationship without giving rise to any right to compensation, without prejudice to the User's outstanding obligations.

29. Territorial restrictions and regulatory compliance

Access to and use of the NEBEUS Platform is reserved exclusively for Users whose residence is in jurisdictions where the Services offered are legal and comply with applicable regulations.

The use of the Platform is expressly prohibited by:

• Residents of the European Union, when the Services involve stablecoins or other virtual assets not authorized under Regulation (EU) 2023/1114 (MiCA). In such cases, the Platform may display informational banners or automatically block access to certain features.

• Residents of the United States of America, except in the case of services expressly authorized and compliant with applicable federal and state regulations (including SEC, FinCEN, and OFAC rules).

• Persons included in international financial sanctions lists (e.g., OFAC, United Nations, European Union) as well as those acting on behalf of entities or individuals designated in such lists, and users who reside or intend to operate from jurisdictions subject to a Call for Action by the FATF.

• Users who intend to access from jurisdictions where cryptoasset services are prohibited or subject to licenses not obtained by NEBEUS.

NEBEUS may apply geolocation mechanisms, document verification, and enhanced due diligence controls to identify and restrict access from prohibited jurisdictions.

The User declares and guarantees, under their sole responsibility, that they are not included in any of the above cases and that they will use the Platform only in accordance with the regulations applicable in their country of residence. Failure to comply with this obligation constitutes grounds for immediate suspension or termination of the Account, without the right to any compensation.

30. Prevention of money laundering, terrorist financing, and cooperation with authorities

NEBEUS, in its capacity as a Virtual Asset Service Provider (VASP) registered with the National Securities Commission (CNV), complies with Law No. 25,246, the regulations of the Financial Information Unit (UIF), as well as the recommendations of the Financial Action Task Force (FATF) and other international organizations regarding the prevention of money laundering and terrorist financing.

Within this framework, NEBEUS may:

• Apply Customer Due Diligence (KYC) and Transaction Monitoring policies, adjusted to a Risk-Based Approach (RBA), which include document verification, analysis of unusual transactions, and establishment of usage limits.

• Suspend, withhold, or reject transactions that appear unusual or raise red flags, or that are incompatible with the User's declared profile.

• Request additional information and documentation at any time, including regarding the lawful origin of funds or the nature of transactions.

• Report suspicious transactions to the UIF and cooperate with other national authorities (CNV, ARCA, BCRA, where applicable) or foreign authorities within the framework of international legal assistance agreements, where applicable.

• Share information with technology and financial providers acting as data processors, always under strict confidentiality and security obligations.

The User accepts that these measures constitute unavoidable legal obligations for NEBEUS and undertakes to cooperate fully, providing accurate and up-to-date information. Failure to comply with this obligation will entitle NEBEUS to suspend or cancel the Account immediately, without prejudice to any civil or criminal liability that may apply.

31. Digital security and user responsibility

Use of the Platform requires the User to take appropriate security measures to protect their credentials, devices, and communications. In particular, the User agrees to:

• Maintain the absolute confidentiality of their access codes, dynamic passwords, verification codes, and other credentials associated with their Account.

• Activate and use strong authentication mechanisms (e.g., two-step verification or "2FA") when required or recommended by the Platform.

• Use the Platform only from personal and secure devices, with updated operating systems, browsers, and applications, free of viruses or malicious software.

• Immediately notify NEBEUS of any unauthorized use, loss, theft, improper access, or suspected breach of your Account security so that preventive measures can be taken.

• Do not share devices or credentials with third parties or allow simultaneous access that could jeopardize the integrity of the Account.

The User acknowledges and accepts that NEBEUS shall not be liable for any loss or damage arising from:

• The User's own negligence in complying with the security obligations set forth herein.

• The misuse by third parties of legitimate credentials obtained due to the User's recklessness or carelessness.

• Failures in third-party devices, networks, applications, or software that are not under the direct control of NEBEUS.

NEBEUS may apply additional technical protection measures, including temporary access blocks, periodic password expiration, and manual verifications, all with the aim of ensuring the security of the Platform and its operations. These measures may cause reasonable delays in the execution of operations, which the User accepts as a necessary condition for preserving the integrity of the system.

32. Transparency and non-abusiveness of clauses

These Terms and Conditions have been drafted in accordance with the principles of transparency, good faith, and contractual balance, in compliance with the Consumer Protection Law (Law No. 24,240), the Civil and Commercial Code of the Nation, and the applicable regulations on adhesion contracts and general conditions.

All clauses contained herein shall be interpreted in such a way as to preserve their validity and effectiveness, avoiding any result that is abusive or contrary to public order. If any provision is declared null, invalid, or ineffective by a competent authority, this shall not affect the validity of the remaining provisions, which shall remain fully applicable.

NEBEUS guarantees that the limitations of liability, exclusions of warranties, powers of suspension or termination, and other contractual provisions have been included only to the extent that they are reasonable, proportionate, and necessary for the operation of the Platform, without depriving the User of the minimum rights recognized by consumer protection legislation.

In case of doubt about the interpretation of any provision, the interpretation that best fits the principle of contract preservation will prevail, considering the nature of the Services, the risks associated with virtual assets, and the need to ensure the security and legality of operations.